The Government plans to reform the audit and corporate governance landscape by introducing a number of reforms. The plans are to implement ARGA by April 2023, with other reforms implemented thereafter.
Expertise
Sarah is ranked as a Leading Partner in Legal 500 for Financial Services (contentious), a band 4 rated partner in Chambers & Partners and is a Recommended Partner in Who's Who (Lexology) for Global Investigations . Sarah has two decades of experience acting for clearing, investment and specialist banks, lenders, fintechs, payments firms, building societies, listed companies, insurance brokers, asset managers and other financial services firms and directors in high profile regulatory investigations by the FCA, PRA, PSR and Financial Reporting Council, and conducting independent public reviews and whistleblowing investigations. She joined Addleshaw Goddard in June 2019 from the London financial services investigations team at Herbert Smith Freehills LLP, and has spent time on secondment at a global wealth management bank. Sarah has particular expertise advising on investigations concerning non-financial misconduct; market abuse; financial crime systems and controls; the FCA’s conduct of business rules; complaints handling; governance and culture; anti-money laundering, consumer redress and client money and assets (CASS). Sarah devised and leads AG's AI-enabled customer redress service, and has conducted a wide range of customer redress exercises.
Sarah is currently leading on motor finance redress and related governance and regulatory risk issues. Our motor finance redress webpage is here and contains all of our thought leadership.
- Experience
Financial Services
- Advising several banks and lending groups in relation to Annex 1 lending registration under the MLRs.
- Advising a financial services group on threatened VDIR and VREQ by the FCA in relation to financial crime compliance.
- Advising a global bank on a whistleblowing investigation into customer redress and application of individual accountability.
- Advising a wealth manager on a whistleblowing investigation into non-financial misconduct by senior management.
- Advising multiple banks and lenders in relation to motor finance commission redress and related risk and litigation issues.
- Advising an investment bank in a whistleblowing investigation into allegations of SMCR breaches and operational risk and governance failings.
- Advising an insurance intermediary in regulatory engagement concerning policy design and distribution and the regulatory perimeter.
- Advising a bank on a solvent wind down and related engagement with the PRA.
- Preparing the CEO and Chair of a systemic infrastructure firm for approval interviews with the Bank of England.
- Advising several PRA regulated financial institutions and listed corporates on whistleblowing investigations relating to regulatory breaches and non-financial misconduct.
- Advising an investment platform in an internal investigation into breaches of the Money Laundering Regulations, POCA and the FCA's systems and controls requirements in relation to financial crime.
- Advising several banks in respect of negotiation of, and legal issues arising from, participation in government lending schemes, including BBLS.
- Advising an insurance intermediary on an FCA enforcement and settlement in relation to sales practices.
- Advising an asset manager in respect of FCA investigations into sensitive non-financial misconduct and SMCR and HR controls.
- Advising a payment firm in respect of an enforcement investigation by the Payment Systems Regulator.
- Advising several banks in customer redress exercises in respect of financial products, bereavement processes and mortgages.
- Advising a global investment bank on an FCA investigation into corporate banking AML systems and controls.*
- Advising a major UK retail bank in respect of regulatory and complaints handling issues, and a past business review, into its sales of fixed rate loans to businesses.*
- Advising a European investment bank on an FCA investigation into the sale and distribution of institutional loan notes.*
- Advising PricewaterhouseCoopers LLP and one of its partners in the successful defence of an FRC investigation into CASS reports to the FCA in respect of Barclays Bank plc.*
- Advising a global wealth management bank on regulatory issues, litigation and FOS complaints handling and related litigation arising from sales of tax efficient film partnership investments.*
- Referral to the Upper Tribunal by an Insurer in relation to a PRA decision.*
Sarah also speaks frequently at industry conferences on a range of topics including whistleblowing, SMCR, FCA enforcement trends, and the CASS rules.
Work relating to market conduct and public companies
- Advising a director of a listed company in relation to an FCA enforcement investigation into the public statements of a listed global energy company.
- Advising a Chairman of a listed group in an investigation in respect of allegations of insider dealing.
- Advising individuals in respect of preliminary enquiries by the FCA regarding market conduct.
- Conducting independent whistleblowing investigations for a FTSE 100 global company in respect of ethical and non-financial misconduct issues.
- Advising an AIM listed company into FCA enquiries arising out of an accounting fraud.
*experience gained prior to joining Addleshaw Goddard
- Education
- Nottingham Law School (2002, LPC)
- University of Cambridge (BA, 2001, Law)
- Languages
- French
- Professional memberships
- Law Society of England and Wales
- Publications
- Thomson Reuters Financial Services Compliance Handbook, Internal Investigations Chapter 2021 edition
- Securities Litigation Review, 5th Edition 2019, pub. TheLawReviews - Chapter on England and Wales (with Harry Edwards)
- Getting the Deal Through – Financial Services Litigation (UK regulatory chapter) 2017 edition
- Thomson Reuters Financial Services Compliance Handbook, Enforcement Chapter (with Jenny Stainsby) 2014 edition
- CASS compliance: legal issues, unfair contract terms, and risks for senior managers. Butterworths Journal of International Banking and Financial Law July 2015 (with Hywel Jenkins)
- "Is it time for firms to reconsider their approach to settling enforcement action?" (with Harry Edwards) Law and Financial Markets Review, November 2013
- Attestations: what they are and what you need to know, Financial News 21 November 2013
- "Trial by Media as a Regulatory Tool", British American Business Industry Insight, vol 1 2013
- "Words' Worth: UK authorities are matching words with action in latest bribery enforcements", New Law Journal, October 2009 (with Alex Rene).
- Recognitions
- Leading Partner - Legal 500 Financial Services (Contentious)
- Band 4 - Chambers Contentious Regulatory
- Testimonials
- "Very professional, strong knowledge and expertise, innovative, commercially minded, collaborative and easy to work with." - Legal 500 2026
- "There’s a real skill in this practice that goes beyond legal competency. They have a way of making you the client feel valued, that you're important, not just a fee payer. From the welcome walking in the door, you feel recognised, looked after, and respected. They are professional, approachable, and always accessible. While this may seem simple, it’s really hard to deliver consistently, but they do." - Legal 500 2026
- "The level of knowledge, engagement, and proactive communication is excellent. You really get a sense that you’ve got people like … Sarah Thomas batting on your behalf. This instills tremendous confidence that you have a strong, motivated team behind you with a tremendous range of expertise and deep bench strength behind the scenes." - Legal 500 2026
- "Sarah Thomas is highly engaged, pragmatic, and thoughtful in her assessment of risks and solutions. Breadth of knowledge and experience applied practically. Great communicator. Exceptional support." - Legal 500 2026
- "It's always a pleasure working with Sarah Thomas. She is a trusted and formidably capable advisor. In the complex and nuanced world of contentious financial services, where the landscape evolves rapidly, it’s essential to have someone who is not only deeply knowledgeable but also confident in delivering clear, robust opinions and standing firmly behind them. Sarah consistently provides that assurance." - Legal 500 2026
- "Sarah is an excellent regulatory lawyer and has the ability to think outside the box. She is very responsive and is able to meet tight deadlines.” - Chambers 2026
- "Very responsive and very thorough, proactive and pragmatic." - Legal 500 2025
- "Grasps complex scenarios with ease and speed. Thoughtful, useful, practical and proactive advice - Sarah's high level of engagement makes her an essential part of any team on sensitive, complex matters." - Legal 500 2025
- "Sarah Thomas is responsive and strategic and goes the extra mile for her clients…she is easy to work with, quick off the mark, understands the issues and brings a reassuring presence." - Legal 500 2024
- Year qualified
England and Wales, 2004
